Recurring Findings

Education: Recurring Less severe Noncompliance

Federal Program

Issue

First Year Reported

Department's Assertion

Page Number

Education Jobs

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure accuracy of the quarterly Section 1512 report prior to submission for the School Improvement Grant Cluster. Similar to the finding in 2011-12, Education prepares the report from information maintained by program personnel but that information is not reconciled to accounting records, such as the general ledger. In addition, the amount reported as disbursed to one local educational agency for the School Improvement Grant was understated by $75,821. Lack of adequate controls over Section 1512 reports increases the risk that inaccurate or incomplete information will be reported to the federal government.

2010-11

Education accepts the recommendation. The reporting error identified by the auditors was corrected on November 13, 2013. Education will ensure that the final report to the federal government reconciles with Education’s accounting records. The ARRA School Improvement grant period is over and the LEA Section 1512 reporting period ended on January 31, 2014.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure accuracy of the quarterly Section 1512 report prior to submission for the School Improvement Grant Cluster. Similar to the finding in 2011-12, Education prepares the report from information maintained by program personnel but that information is not reconciled to accounting records, such as the general ledger. In addition, the amount reported as disbursed to one local educational agency for the School Improvement Grant was understated by $75,821. Lack of adequate controls over Section 1512 reports increases the risk that inaccurate or incomplete information will be reported to the federal government.

2010-11

Education accepts the recommendation. The reporting error identified by the auditors was corrected on November 13, 2013. Education will ensure that the final report to the federal government reconciles with Education’s accounting records. The ARRA School Improvement grant period is over and the LEA Section 1512 reporting period ended on January 31, 2014.

During our audit for fiscal year 2011-12, we reported that Education lacked adequate controls to ensure it met maintenance of effort (MOE) requirements and did not request a waiver from the Federal Department of Education. In fiscal year 2012-13, Education again did not meet its MOE requirement by $93,351,516, nor did it request a waiver.

2010-11

Education has internal controls in place to ensure MOE requirements are met in accordance with federal regulations. However, the Legislature controls the appropriations that provide financial support for services to students with disabilities across state agencies, not Education. Education exercises full control over the distribution and expenditures of the allocations it receives, but has no control over the financial support appropriated by the Legislature and approved by the Governor. Education monitors the budget process; if the proposed budget threatens the State’s ability to meet federal Maintenance of Effort (MOE) for the Individuals with Disabilities Education Act (IDEA), Education promptly notifies the Legislature of the potential shortfall. Throughout the year, Education obtains information regarding funds other state agencies provide directly to LEAs for special education services and any state funds other agencies directly pay to staff or contractors for the delivery of services pursuant to an Individualized Education Program. At this time, other state agencies have not finalized the actual expenditures for calculating fiscal year 2011–12 Special Education MOE. Once Education obtains the final expenditure data from the other state agencies, Education will assess compliance with federal MOE requirements. If the expenditure data demonstrates that state financial support did not meet MOE requirements, Education will request the necessary funding from the Legislature. However, if the Legislature does not provide Education with sufficient funding to meet MOE requirements, Education will seek a remedy from the federal Office of Special Education Program.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

Child Care Mandatory and Matching Funds of the Child Care and Development Fund

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we found that Education does not review or evaluate the counts of migrant students. Education uses the Migrant Student Information Network (MSIN) to collect child count data which is submitted on the Consolidated State Performance Report (CSPR) to the U.S. Department of Education. MSIN is owned by, and the data collection process is managed by, a nonprofit organization on behalf of Education. Education relies on the nonprofit organization to establish the system of quality controls required by federal regulation and ensure an accurate count of migrant students. Furthermore, Education does not review or evaluate the information obtained by the nonprofit organization. As a result, Education may not report accurate information to the federal government.

2011-12

Education accepts the recommendation. In 2012–13, Education matched Migrant Student Information Network (MSIN) data with data from the California Longitudinal Pupil Achievement Data System (CALPADS) and determined that 93 percent of students in kindergarten through twelfth grade had a valid Statewide Student Identifier (SSID). Education will continue this matching process in 2013–14 and forward. In addition, Education will implement a new data reconciliation policy whereby MEP staff will work with local district CALPADS administrators to review and reconcile student files. To further improve the quality of data accuracy, Education’s nonprofit data management organization provides Education biweekly updates on pending and incorrect information found in MSIN. Education reviews these reports and contacts regions to provide technical assistance to remedy any identified data quality issues. In September 2013, Education developed the enclosed 2013–14 Migrant Education Office Plan for Obtaining and Verifying SSIDs. In November 2013, Education commenced implementation of the plan; full implementation is scheduled for March 1, 2014.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not fully implement adequate controls to ensure that it documented approval of food service management company contracts within the Child Nutrition Information and Payment System (CNIPS) prior to reimbursing subrecipients. Although the School Food Service Contracts Unit was created to ensure compliance with federal requirements, the unit was not able to review 16 of 38 contracts for fiscal year 2012-13. Education’s failure to properly approve food service contracts increases the risk that such contracts may not comply with federal regulations.

2011-12

Education accepts the recommendation. To ensure compliance with federal requirements prior to subrecipients’ application renewal and reimbursement of federal funds, Education’s School Food Service Contracts Unit (SFSCU) reviews and approves food service management company contracts submitted to Education; SFSCU approvals are documented in CNIPS to allow the disbursement of nutrition program funds to subrecipients. The SFSCU: • Reviewed 83 FSMC contracts and contract extensions for the 2013–14 school year • Required SFAs that are operating under extensions of their original FSMC contract to correct problems identified in their original procurement process through amendments to their current extension requests • Assisted the School Nutrition Programs Unit (SNPU) with their annual updates in CNIPS, which helped educate SFSCU staff on SFA CNIPS application protocols, school meal program requirements, and CNIPS FSMC protocols • Improved Education’s Food Service Management Procurement Web page • Developed a sample FSMC Request for Proposal (RFP) and model Contract, and: »» Held a stakeholder meeting in December 2013 with FSMC representatives and Education staff to review the draft sample FSMC RFP and model contract »» Posted the sample FSMC RFP and model Contract in December 2013 to Education’s Food Service Management Procurement Web page »» Incorporated feedback from FSMC Representatives, public school districts, and the USDA and will post the revised sample RFP and model Contract in February 2014 • Created a Microsoft Excel contract tracking system to identify and notify SFAs that are due to rebid their contracts and to track review activities to ensure that both Education and SFAs are being responsive to the established review timeline • Submitted a CNIPS change request (CR) to improve functionality of the CNIPS FSMC Fact Sheet to better track the contract approval process (Note: CR is estimated to be implemented in 2015) • Completed the week-long U.S. Department of Agriculture (USDA) Administrative Review Training in San Francisco (SFSCU Manager only) • Completed online National Food Service Management Institute State Agency Guidance procurement training (SFSCU Manager and staff) The SFSCU is currently: • Reviewing and approving all procurement documents, including contracts, for FSMC contract rebids for the 2014–15 school year • Reviewing and approving FSMC contract extensions for the 2014–15 school year • Customizing the current Sample Fixed-Fee RFP and Contract • Developing a Sample Cost-Reimbursable RFP and Contract • Conducting weekly staff meetings to discuss contract review status, issues, and projects • Developing Webinars to educate SFAs on procurement laws and regulations and Education’s FSMC contract review and approval process (first Webinar scheduled for May 2014) • Participating in the new USDA Administrative Review Task Force to develop State Agency SFA/ FSMC oversight procedures.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not fully implement adequate controls to ensure that it documented approval of food service management company contracts within the Child Nutrition Information and Payment System (CNIPS) prior to reimbursing subrecipients. Although the School Food Service Contracts Unit was created to ensure compliance with federal requirements, the unit was not able to review 16 of 38 contracts for fiscal year 2012-13. Education’s failure to properly approve food service contracts increases the risk that such contracts may not comply with federal regulations.

2011-12

Education accepts the recommendation. To ensure compliance with federal requirements prior to subrecipients’ application renewal and reimbursement of federal funds, Education’s School Food Service Contracts Unit (SFSCU) reviews and approves food service management company contracts submitted to Education; SFSCU approvals are documented in CNIPS to allow the disbursement of nutrition program funds to subrecipients. The SFSCU: • Reviewed 83 FSMC contracts and contract extensions for the 2013–14 school year • Required SFAs that are operating under extensions of their original FSMC contract to correct problems identified in their original procurement process through amendments to their current extension requests • Assisted the School Nutrition Programs Unit (SNPU) with their annual updates in CNIPS, which helped educate SFSCU staff on SFA CNIPS application protocols, school meal program requirements, and CNIPS FSMC protocols • Improved Education’s Food Service Management Procurement Web page • Developed a sample FSMC Request for Proposal (RFP) and model Contract, and: »» Held a stakeholder meeting in December 2013 with FSMC representatives and Education staff to review the draft sample FSMC RFP and model contract »» Posted the sample FSMC RFP and model Contract in December 2013 to Education’s Food Service Management Procurement Web page »» Incorporated feedback from FSMC Representatives, public school districts, and the USDA and will post the revised sample RFP and model Contract in February 2014 • Created a Microsoft Excel contract tracking system to identify and notify SFAs that are due to rebid their contracts and to track review activities to ensure that both Education and SFAs are being responsive to the established review timeline • Submitted a CNIPS change request (CR) to improve functionality of the CNIPS FSMC Fact Sheet to better track the contract approval process (Note: CR is estimated to be implemented in 2015) • Completed the week-long U.S. Department of Agriculture (USDA) Administrative Review Training in San Francisco (SFSCU Manager only) • Completed online National Food Service Management Institute State Agency Guidance procurement training (SFSCU Manager and staff) The SFSCU is currently: • Reviewing and approving all procurement documents, including contracts, for FSMC contract rebids for the 2014–15 school year • Reviewing and approving FSMC contract extensions for the 2014–15 school year • Customizing the current Sample Fixed-Fee RFP and Contract • Developing a Sample Cost-Reimbursable RFP and Contract • Conducting weekly staff meetings to discuss contract review status, issues, and projects • Developing Webinars to educate SFAs on procurement laws and regulations and Education’s FSMC contract review and approval process (first Webinar scheduled for May 2014) • Participating in the new USDA Administrative Review Task Force to develop State Agency SFA/ FSMC oversight procedures.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.

During our audit for fiscal year 2011-12, we reported that Education did not have an adequate process or controls in place to ensure information required by the Federal Funding Accountability Transparency Act (FFATA) was properly reported for each of its federally funded programs. Similar to fiscal year 2011-12, Education only reported subaward information for the Career and Technical Education – Basic Grants to States program in fiscal year 2012-13 but did not report information for any other programs. Failure to implement adequate controls over FFATA reporting increases the risk of late or nonsubmission of subaward information.

2011-12

Education accepts the recommendation. During fiscal year 2012-13, Education implemented a reporting schedule and designed processes that would ensure compliance with the requirements of the Federal Funding Accountability Transparency Act Subaward Reporting System (FSRS). As a pilot, Special Education data was successfully uploaded to the FSRS; Education anticipates that information for other federal programs will be uploaded to the FSRS accordingly.